Daily Blast June 13, 2014

Division One of the Second Appellate District Court of Appeal (Los Angeles), issued an opinion in Uriarte v. Scott Sales Co. (June 13, 2014, B244257) __ Cal.App.4th ___, analyzing the component parts doctrine. The court held that because the plaintiff’s “injuries were allegedly caused by the use of the silica sand during the manufacturing process, rather than by the finished product that was produced by that process, the component parts doctrine does not apply.” (Slip opn., p. 2.)

Plaintiff worked as a sandblaster for Lubeco. Inc. (“Lubeco”). Defendants J.R. Simplot Company (“Simplot”) and Scott Sales Co. (“Scott”) supplied silica sand to Lubeco, for use as sandblasting media. Plaintiff sued Simplot and Scott and other defendants alleging causes of action for negligence, negligence per se, strict liability for failure to warn, strict liability for design defect, fraudulent concealment, and breach of implied warranties. (Slip opn., p. 2.) Plaintiff alleged that the airborne toxins produced by sandblasting with defendants’ silica sand caused him to develop interstitial pulmonary fibrosis and other illnesses. Simplot and Scott successfully moved for judgment on the pleadings on the basis of the component parts doctrine, which provides that “the manufacturer of a component part is not liable for injuries caused by the finished product into which the component has been incorporated unless the component itself was defective and caused harm.” (Ibid. quoting O’Neil v. Crane Co. (2012) 53 Cal.4th 335, 355.) Plaintiff appealed.

The Court of Appeal reversed. The court explained that plaintiff did not allege that the silica sand supplied by Scott and Simplot was incorporated into finished products that caused him harm. Indeed, he never alleged that his injuries were caused by Lubeco’s finished products. (Slip opn., p. 5.) Rather, he alleged that Scott’s and Simplot’s silica sand was used in Lubeco’s manufacturing process in the manner intended by Scott and Simplot, and that he was injured in the course of that process by that intended use of the silica sand. Thus, plaintiff’s theory of liability did not require Scott or Simplot to scrutinize Lubeco’s products or review Lubeco’s business decisions. (Ibid.) Scott and Simplot need only scrutinize their own products and warn about the scientifically known dangers of using those products in the manner that Scott and Simplot intend them to be used. Thus, the component parts doctrine did not apply. (Id. at pp. 5-6.)

Further, the court disagreed with the interpretation and application of the component parts doctrine articulated in Maxton v. Western States Metals (2012) 203 Cal.App.4th 81, and thus joined the recent decision in Ramos v. Brenntag Specialties, Inc. (2014) 224 Cal.App.4th 1239, 1255, which held that “the component parts doctrine does not target claims by a party alleging that he suffered a direct injury from using a product as the supplier specifically intended.” (Slip opn., pp. 2, 9.) The court stated that “[no] California case other than Maxton has extended the component parts doctrine to apply to injuries caused during the manufacturing process in which the defendant’s product was used as intended, rather than injuries caused by the finished product that was the result of that process.” (Id. at p. 8.)

All three cases, Maxton, Ramos and now Uriarte, are the products of the Metzger law group of Long Beach, California. All three emanate from different divisions of the Second Appellate District Court of Appeal – Maxton (Div. Three); Ramos (Div. Four) and Uriarte (Div. One). I would not be surprised if Ramos and/or Uriarte made its way the California Supreme Court for settlement of this conflict. The Ramos petition for review is now pending before the Supreme Court.